Romania

Transfer Pricing in Romania

Romanian transfer pricing for tax year 2026: who is an affiliated person (Fiscal Code art. 7 pt. 26, the 25% holding or effective control test), the arm's length rule and the five methods (art. 11(4)), the transfer pricing file (dosarul prețurilor de transfer) under Fiscal Procedure Code art. 108(2) and ANAF Order 828/2026 (which replaces Order 442/2016 for 2026 transactions), the large taxpayer thresholds per affiliated person (EUR 100,000 services / 200,000 interest / 250,000 intangibles and royalties / 350,000 tangible goods), preparation by the corporate tax return deadline and filing in SPV within 30 working days, the on-request regime for small and medium taxpayers (EUR 50,000 / 100,000 / 150,000 / 200,000, 30 to 60 working days to present), the interquartile range and the median adjustment, APAs and their EUR 10,000 / 20,000 fees, the RON 2,000 to 14,000 fine for not preparing or presenting the file, and country-by-country reporting.